On January 29, 2021, the European Commission (EC) closed its feedback period on its Inception Impact Assessment (IIA) within an ongoing process to revise its rules on food contact materials (FCMs) (FPF reported). In total, 302 comments were submitted including from business operators, trade associations, private citizens, and civil society organizations.

The Food Packaging Forum (FPF) submitted comments during this period on the EU’s plans for improving its FCM regulation. In its comments, FPF focused on amending the safety definition in the FCM Framework Regulation. The current definition (EU 1935/2004) assumes that for any chemicals a safe level of exposure can be set. But for some chemicals, such as carcinogens or endocrine disrupting chemicals, as well as for mixtures of chemicals, safe exposure levels are challenging to identify. Therefore, FPF suggests that this fact be included in a revised definition of safety to account for current scientific understanding.

FPF also offers the European Commission its support for prioritizing chemicals of most concern. In 2020, FPF together with external scientific collaborators published a database of food contact chemicals (FCCdb; FPF reported) that are intentionally used in the manufacture of FCMs globally. FPF used a peer-reviewed method for prioritizing FCCs based on the available hazard data. This approach may be of use for identifying chemicals of highest concern for priority regulatory action.


Food Packaging Forum (January 29, 2021). “Revision of EU rules on food contact materials: Inception Impact Assessment.” (pdf)

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EC (January 29, 2020). “Revision of EU rules on food contact materials.